Registration Guidelines for Minor uses (Minor crops) in South Africa 2010 1
TABLE OF CONTENTS 1.0 Introduction 3 2.0 General minor use definition 3 3.0 List of minor crops 4 4.0 Requirements for registration 4 4.1 Toxicological data 6 4.2 Efficacy/phytotoxicity trials 6 4.3 Residue trials 7 4.4 Registration incentives 7 5.0 Data extrapolation 7 6.0 Extrapolation table 7 2
1.0 INTRODUCTION The lack of remedies to control pests on minor crops results in the creation of barriers with international trading partners. Illegal use of pesticides becomes common. Human and environmental health may be adversely affected due to the misuse of pesticides. In order to approach the problem of minor crops in South Africa, creative solution will have to be established in order to help growers to engage in sustainable businesses. It should be noted that the requirements to register minor crops remedies should be slightly different from that used to register pesticides for major crops. Therefore data extrapolation will be used to circumvent the costs associated the generation efficacy data and by offering incentives in order to encourage applicants to include minor crops on their labels. The purpose of these guidelines is to overcome registration hurdles encountered when applying for registration of minor crop products/pesticides. These guidelines are aimed at expediting minor use pesticide registrations in situations where there is no or limited pesticide registered for a specific indication in South Africa and they must be read in conjunction with all other registration guidelines published by the department in order to fully comply with registration requirements. These will ultimately afford growers more alternatives in their farming endeavors. 2.0 General Minor Use Definition Minor use as defined in by CODEX alimentarius commission is the use of chemical pesticides or-non chemical means of crop protection where the potential use is on a scale not sufficiently large to justify registration of that use from applicant s perspective alone. The key driver for minor uses is a lack of economic return to an applicant from registering those uses, in particular the associated costs of generating the data required for obtaining and maintaining regulatory approval and potential liability from those uses once approved. Minor uses involve crops grown on a small scale (minor crops) and often are high value crops. Additionally minor uses can involve uses within major crops in terms of controlling minor pests and diseases. This results in a situation where specialty crop industries are either left without or are lacking sufficient access to pesticides to adequately protect their crops. 3
In South Africa, minor uses of agricultural remedies are defined as those desired uses of registered agricultural remedies for which the anticipated increase in the volume of sales is not sufficient to persuade the manufacturer or registration holder to carry out the research required for registration. This definition emphasizes that it is the projected increase in annual sales of the remedies that are minor, not necessarily the crop or pest. In order to simplify the mater, a common sense approach was used in compiling a list of minor crops following a consultative process and such a list together with the extrapolation table can only be expanded or edited by the office of the Registrar after receiving convincing motivation regarding a particular crop to be listed as minor crop. The listed crops below will be used in conjunction with the extrapolation table below. It must be recognized that there will be situations where data extrapolation will not be possible using crop grouping, and therefore data regarding efficacy, phytotoxicity and residue should be generated for the specific crop. 3.0 LIST OF MINOR CROPS 1. Artichokes/Asparagus/Celery/Rhubarb 2. Apricots/Nectarines/Peaches 3. Aubegines 4. Barley/Oats 5. Beetroot 6. Broccoli 7. Broccoli seedlings 8. Brussels sprout 9. Blueberry/currents/Goosebery/Raspbery 10. Butternut/pumpkins/marrows/patty pans/squash 11. Canola 12. Carrots 13. Capsicum 14. Cauliflower 15. Celery 16. Chicory 17. Chillies 18. Cherries/Plums/Prunes 19. Chinese cabbage 20. Chive 21. Clover 22. Courgettes 23. Fennel 24. Figs 25. French endive 4
26. Fresh dates 27. Garlic 28. Ginger 29. Green beans 30. Indigenous leafy vegetables (e.g.amaranthus spp, Solanum nigrum, Cucurbits, Vigna unguiculata, Cleome monophylla, Chorcorus trilocularis, Bidens pilosa, Citrullus lanatus etc) 31. Indigenous Fruits 32. Kiwi fruit 33. Kumquats 34. Leek 35. Limes/Lemons/Mandarins 36. Lettuce 37. Litchi 38. Lucerne 39. Lupins 40. Macadamia 41. Onions 42. Onion seedlings 43. Okra 44. Olives 45. Papaya 46. Parsley 47. Passion fruit 48. Patty pans 49. Peas 50. Pecan nuts 51. Pepinos 52. Peppers 53. Persimmons 54. Pistachio 55. Plums 56. Pomegranate 57. Prickly pears 58. Quinces 59. Radish/Horseradish 60. Raspberry/Blackberry 61. Rhubarb 62. Ryegrass 63. Spinach 64. Sorghum 65. Sweet corn 66. Sweet pepper seedlings 67. Sweet potato 68. Strawberry 69. Sugar beet 5
70. Tngerines 71. Turnips 72. Walnut 73. Water melons 4.0 REQUIREMENTS FOR REGISTRATION Registration application forms Registration fee Toxicological data Five batch analysis (Technical Material) done by GLP/ISO17025 accredited laboratory Efficacy/phytotoxicity data (VISUAL ASSESSEMNTS) Residue data 4.1 Toxicological data In case where the product is not registered in South Africa, toxicological data will be required. If a product is already registered in the EU; USA, JAPAN and AUSTRALIA locally generated efficacy and phytotoxicity data will suffice in applying for temporary registration, however such registrations must be accompanied by a toxicology report from an independent toxicologist, temporary registration will be given pending the evaluation of the toxicology dossier by the Department of Health. However registration certificates and other documents must be submitted in order to support such applications. 4.2 Efficacy/Phytotoxicity Locally generated efficacy and phytotoxicity data will suffice in applying for registration. The following must clearly be outlined on the label, crop, pests, rate of application, and number of application timings, pre harvest intervals, and growth stages of both the pest and the crop. Minor crop growers may also generate their own data in order to increase the number of pesticides available in dealing with problems that they may be experiencing. However, good agricultural practices and proper trial methodology have to be followed in order to generate high quality data. As a general rule a minimum of three trials will be required per crop. 6
4.3 Residue Trials Local generated residue data have to be submitted depending on whether a product in question is a generic or new active ingredient. Residue trials guidelines must be followed when conducting residue trials. 4.4 REGISTRATION INCENTIVES The Registrar will offer the applicant incentives as indicated below if the applicant had met or exceeded the requirements in terms of the number of minor crops listed on the label. Extending data protection to the original registrant if a minimum of five minor crops are included on the label (5 years). Extending data protection on mixtures and formulations, if the registration includes a minimum of five minor crops on the label (5 years). 5.0 DATA EXTRAPOLATION The CODEX crops groupings will be used to extrapolate data (efficacy data) from one crop to another if the crops in question belong to the same group. It should be remembered that data extrapolation will only be used for those crops listed or identified as minor crops. However residue data extrapolation will not be considered when extrapolating efficacy data from one crop to another, and therefore residue will have to be generated from a specific crop. It should be noted that there will be situations were crop grouping will not allow data extrapolation as indicated on the Table below, and therefore efficacy data will have to be generated from those specific crops where extrapolation is not possible as indicated on the Table below. 7
6.0 EXTRAPOLATION TABLE (CODEX CROP GROUPING) CROP GROUP CROP GROUP MEMBERS IN SA 1. Citrus Subgroup 1 Lemons Lime Mandarins Subgroup2 Grapefruit Oranges Tangerines 2.Pome fruit Apple Pear Quince 3. Stone fruit Subgroup 1 Apricot Nectarines Peach DATA EXTRAPOLATION (Discussion needed) Whole group Whole group Whole group is 4.Berries and other small fruit Cherries Plums Prunes Subgroup 1 Blackberry Raspberry Blueberry Currents Gooseberry Other group According to subgroups 8
5&6.Tropical subtropical fruit and Grapes Strawberry Dates Figs Avocado Banana Guava Kiwifruit Litchi Mango Pawpaw Passion fruit Persimmons Pecan nuts Pineapple Not possible. Not possible, data need to be generated from each crop Other (indigenous fruit) Marula Prickle pear 9.Bulb Vegetables Subgroup 1 Garlic Onions According to subgroups Subgroups 1,2 and 3 possible to extrapolate. Chives Spring onions Subgroup 3 Leeks Subgroup 4 Fennel bulb 10.Brassica Vegetables Subgroup 1 The whole group Cauliflower Broccoli 9
Cabbage Subgroup 3 Brussels sprout 11.Fruiting Cucurbits Vegetables Subgroup 1 Cucumber Patty pans Whole group Melons Marrows Pumpkins Squash Melons to be considered separately 12.Fruiting Vegetables Subgroup 1 Egg plant Tomato Not possible for subgroups 1 & other. 13.Leafy Vegetables (including brassica leafy vegetables) Fungi Mushroom Other: Peppers Chilies Cape gooseberry Sweet corn Okra Subgroup 1 Lettuce Mustard Spinach Subgroup 3 According to subgroups and subgroup 4, individual vegetables should be considered on their own. 10
14.Legume Vegetables (succulent seeds and immature pods) 15.Pulses Dry: 16.Roots and Tuber Vegetables: Fennel Subgroup 4 Chinese cabbage Other (Indigenous Vegetables) e.g. Amaranthus spp Bidens pilosa Chenopodium album Solanum nigrum, Vigna unguiculata, Cleome monophylla, Chorcorus trilocularies, Bidens pilosa, Citrullus lanatus etc) Beans (green) Peas (green) Peas Beans Chickpea Lupin Soybean Subgroup 1 Carrots Parsnips Asparagus Beetroot Turnip Subgroup 3 Potato Sweet potato Subgroup 4 Radish Horseradish Whole group except Lupin According to subgroups 11
Subgroup 5 Chicory 17.Stalk and Stem Artichoke Vegetables: Asparagus Celery Rhubarb 20.Cereal Grains: Subgroup 1. Wheat Triticale Whole group except Rhubarb Combine subgroup 1 and 2 Barley Oats Subgroup 3 21. Grasses for sugarcane and syrup production: Maize Sorghum Millet Sugarcane 22. Tree and Nuts Almonds Cashew Chestnuts Hazelnuts Macadamia Pecan Pistachio Walnuts 23.Oiseeds: Subgroup 1 Mustard seed Whole group According to subgroups Sunflower seed Subgroup 3 Peanut Subgroup 4 Soybean Subgroup 5 12
24.LEAF/Seed Beverage: for Olives Coffee TEA Not possible to extrapolate. ROOIBOSS 27. Herbs Many 28.Spices Many Comments can be directed to Mr. Thilivhali Nepfumbada E-Mail: thilivhalin@nda.agric.za TEL : 012 319 6979 13